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Questionnaires

Year

2007-2008

QUESTIONNAIRES

Office of the Information Commissioner of Canada

Report Card Questionnaire

2007-2008

May 14 2008

A. ACCESS TO INFORMATION REQUESTS PROCESS

1. Profile of Requester

Source

Number of requests We have included only those received (but not necessarily completed) to be in line with the Statistics provided in the Annual Report to Parliament.

If Yes, please list and define the categories and if possible indicate the number of access requests in each category.

Category

Definition of Category

Number of requests2007-2008

2.2– If yes, who makes the determination of the category?

N/A

2.3– If yes, is there a specific process related to this categorization? Please provide any relevant information to support the answer.

N/A

3. Client Service

3.1 – On average, how much time does it take your institution to make a final decision on an ATI request under theAct? i.e. What is the total amount of time taken between the receipt of the ATI request and the final decision on disclosure of requested information?

This is interpreted as the average time between receipt of the request and the closing of the request. Number of files completed during reporting period: 1,541 Number of days in total to respond to all requests: 13,2879 Average = 86.2 days Additional information provided to the OIC on June 27, 2008: 86.2 days is the average time between receipt and closure of all requests completed in the reporting period. This is calendar days. This figure includes all requests completed in 2007-2008, including requests received prior to April 1, 2007. Yes, it includes extensions.

3.2 – Disclosure to Requester

Breakdown from Annual Report

Number of requests received during the reporting period (April 1, 2007 to March 31, 2008)

1779

Number of requests completed during the reporting period (April 1, 2007 to March 31, 2008)

"Treated informally" means that we received a formal request for records under the Act. During the processing, the applicant agreed to treat the request informally and receive the documents directly from an OPI or the internet or some other method outside of the Act. The other 656 requests are requests sent to our reading room for records that were previously disclosed to another applicant. The applicants request the records from those listed at this part of our sitehttp://www.admfincs.forces.gc.ca/daip/new_e.asp?sel=atip where ND list previous disclosures. Since these requests are never formally made under the Act, they are not part of the 1,541 completed for that year.

3.4 – Transfers Profile

Transferred within 15 days

11

Transferred after 15 days

3

Total transferred

14

Transfers refused

0

3.5 – Consultations

Received:

Number of consultations received

411 (Additional information provided to the OIC on June 27, 2008: 344 were completed in 2007-2008)

Number of pages to review

41,969

(This question is to be answered by the Privy Council Office (PCO) only) Number of consultations received from other federal institutions related to Cabinet confidences (Please, consult with PCO Legislation and House Planning) (s. 69)

Affairs and(This question is to be answered by the Department of Foreign International Trade only) Number of consultations received from other federal institutions related to International affairs, defence and national security (s. 15)

(This question is to be answered by Canada Border Services Agency and the Royal Canadian Mounted Police only) Number of consultations received from other federal institutions related to law enforcement and penal institutions (s. 16)

For completed requests only, average time spent to review pages received for all consultations

AC Requests Type (Received & Closed) 41 days

Sent:

Number of consultations sent

714

Number of pages sent for review

87,860

Number of consultations sent to PCO Legislation and House Planning related to Cabinet confidences (s. 69)

203

Number of consultations sent to any institutions related to International affairs, defence and national security (s. 15)

127

Number of consultations sent to any institution related to law enforcement and penal institutions (s. 16)

6

For completed requests only, average time to receive responses to all consultations sent

Not available

For completed requests only, average time to receive responses to consultations sent in relation to Cabinet confidences (s. 69)

Not available

For completed requests only, average time to receive responses to consultations sent in relation to defence and national security (s. 15)

Nil

For completed requests only, average time to receive responses to consultations sent in relation to law enforcement and penal institutions (s. 16)

14.2 days

Additional information provided to OIC on June 27, 2008:

ATIPflow cannot generate a report with average days for receipt of response to consultations completed. We can generate a report that calculates the average response time to consultations undertaken during the reporting period but it won't sort it by "completed requests". It will include all consultations taken during the reporting period whether they were completed or not. After reviewing the report of all consultations for PCO (the 203 reported under "sent"), there were only 2 still open so it shouldn't skew the numbers too much. Including those 2 the average time for response by PCO to consultations was 67.11 days. If we do the same for all consultations (including those still open) we get 57.57 days. We don't have an action code for consulting specifically with DFAIT except for those consultations requiring consult with foreign governments - there were 12 of those with an average response time of 199.25 days and 4 of those were still awaiting a response. We can generate a report that shows 88 other consultations were undertaken with DFAIT but the report does not give an average response time (and keep in mind that those consultations aren't necessarily for section 15).

3.6 – Of the total number of access to information requests received during the reporting period, what percentage of these requests required your institution to consult (under paragraph 9(1)(b)) with other federal institutions)?

3.7 – Does your institution have in place a policy, a practice or another instrument, such as a protocol (written or not, please specify), to address how consultations received from another institution or sent to another institution or to a third party, are processed?

Yes

X

No

All consultations are conducted using the Act as a guide for the timelines and in accordance with Treasury Board Guidelines and directives. DAIP has standard letters for different types of consultations and due dates are generated by our software (currently ATIPflow). The general process for consultations is described in DAIP Standard Operating Procedures (SOP), which have been attached as a Word document accompanying this survey. The PCO consultations are explained in more detail in the SOP than are the other types of consultations. DAIP is continuing to expand the SOPs to include the specific details of all actions, including consultations, but we are not there yet. The Policy and Training team will be continuing this update in July 08. In the meantime, any procedural details not covered in the SOPs are taught to ATIP analysts by their mentors and Team Leaders who supervise the application of those procedures. The DAIP Policy and Training section conducts training sessions not only for DAIP staff but also for thousands of DND/CF employees each year. During these training sessions, the consultation process is explained in some detail. For DAIP staff this is merely an introduction, as the details of the process are reinforced during individual instruction and guidance within their teams.

3.8 – Priority: Are consultations processed on a priority basis?

Yes

X

No

All incoming consultations are assigned to a specific Deputy Director who has these consultations as one of her primary tasks. They are not sent to a processing team, which allows those teams to concentrate on processing requests and outgoing consultations. All outgoing consultations are prepared and send as the need for consultation is identified while the file is being processed. Additional information provided to OIC on June 27, 2008: The SOPs are currently concerned with the overall process and do not contain all details of each process (such as consultations received are assigned to a Deputy Director in the ATIP Office). We are working on that. It is not clear in the SOP guidelines. However, when a consultation is received from another department it is opened in the front office with a file number beginning with "AC" (Access Consult). Regular access requests have a file number beginning with "A". There are 2 other deputy directors (DD1 and DD2) who review and sign off the "A" files. If they received an "AC" file they would recognize that and give it to DD3 who is in charge of reviewing and signing off on AC files before they are returned to the OGD. The DDs know what type of file they have to review and sign off. They all have signing authority in the designation order.

4. Time to Process Requests

4.1 Processing Model - Stages

Days Allocated

Average Actual Days

Access to Information and Privacy (ATIP) intake

1

1 (approximate number – not allocated in ATIPflow but this is the expected time and it is normally one day or less)

OPI search

14 days allocated to the OPI for document retrieval and preliminary recommendations. This time period includes any necessary review by the Information Support Team (IST), which reviews files pertaining to CF operations.

23.96

Records review

4 days allocated to DAIP analyst for review

4.63

Records preparation

4 days allocated for triage, scanning and indexing before the analyst begins records review

3 (approximate number based on the average of 3 separate functions)

Legal

Not part of the process

Communications

2 days. This includes Ministerial Heads-Up

0.53

Approval or otherwise – ATIP

2 days The great majority are completed in this time frame but a relatively small number of large and complex files skews the average.

5.82

Approval or otherwise – OPI

Not part of the process

Approval or otherwise – DMO

Not part of the process. A Ministerial Delegation Order is in place

Approval or otherwise - MO

Not part of the process. See above

ATIP release

2 Days allocated for preparing the records for release

1.54

Additional information provided to the OIC on June 27, 2008:

To the OIC question: How do you distinguish 40.48 (q. 41 Average actual days) from 86.2 days (A3. Client service - 3.1)?

Mainly it is because you have to add the amount of time for extensions. The actual life cycle of a request can be much more complex than the handful of stages which you provided. As noted above, the average time for all consultations is 57.57 days. Add that to 40.48 and you get about 98 days. Still not the same but that's statistics for OIC. OIC calculate with two different sets of data and you get different responses.

4.2 – Other than the stages identified in 4.1, does your institution have in place other approval or review processes for requests that are categorized in a special manner as in A.2 above? If yes, please list them.

As briefly noted beside OPI Search in 4.1 all files containing information of an operational nature are sent by the OPI to the Strategic Joint Staff Information Support Team (SJS IST) for an operational security review. If the OPI identifies that the documents proposed for release contain information of an operational nature they are required by IST to consult with them before sending the response on to DAIP. For this reason it is an additional approval process but the review and approval time is part of the 14 days allocated to the OPI by DAIP. These files are not “categorized” any more than is a file sent by an OPI for any other sort of review by a subject matter expert (legal, technical, etc..) prior to returning it to DAIP for processing. The files are not tagged, renamed or otherwise specially identified by DAIP for particular treatment. Additional information provided to the OIC on June 27, 2008:The role of SJS IST is to review operational information and (like all OPIs) to make recommendations for exemptions. Only the Minister (as the actual head of the institution) can supersede DAIP authority. That is why there is a designation order. Additional information provided to OIC on September 12, 2008: Last year IST was reviewing all of the previously released documents (the Informal Access files) pertaining to operations as discussed and it was slowing down what was normally a very quick service. Eventually they asked that we send them only files containing subject matter that they were not likely to be familiar with mainly because they were becoming more knowledgeable regarding the application of severances on past files but also because the previous releases were contributing to a backlog and that review was detracting from their ability to respond to current ATI requests. When it became our discretion (this was tasked to the same Deputy Director who handles the consultations from other government departments) we didn't send very many. At this point we have stopped sending them previously released files entirely. We haven't sent any to them at all in 2008. The main point is that it was initially a problem but it is not any longer. Since most of the files sent to IST are sent directly by the OPI it is impossible to accurately calculate the average amount of time this review has added to the processing time. However, a few organizations send us an email when they send the consultation to IST and some files are sent to IST by us for consultations including consultations from other government departments. Calculating the average time for IST to respond to those consultations we arrive at a number of approximately 33 days. Recent changes that have made it difficult to respond quickly or in a timely manner. In the past year or so there has been a large increase in the number of requests for documents within DAIP, particularly for processing files (where an applicant submits a request and after receiving a response, submits another request for all of the documents concerning the processing of his first request). This can be confusing and time consuming because we are both the tasking organization and the OPI. We must task ourselves. If a team leader receives a tasking, she must stop reviewing the files of her analysts in order to locate records and make recommendations for severance like any other OPI. Then it must be reviewed and signed off (by the director) and sent back to the tasking team and sent to a processing team for review again (to see if we agree with the OPI recommendations) and signed off ultimately by a Deputy Director. There is a bit of coordination to be done in order to ensure the same people who processed the first file aren't reviewing their own notes etc... and making recommendations on their own file and that whoever signs off as OPI is not signing off as DAIP.

Stage name

Days allocated

Average actual days

SJS IST review

Included in OPIs 14 days but expected turnaround is 4 days so as to enable the OPIs to meet their due date.

Since the files are sent directly by the OPI to the IST and back to the OPI DAIP does not track the amount of time each file is under IST review.

4.3 – If other approval or review processes in place, for each stage, please explain in as much detail as possible the rationale for, and purpose of this additional approval or review stage.

Due to operational security issues SJS IST, the CF specialists in the field of operational security (OPSEC), reviews all information regarding CF Operations from an OPSEC perspective. This process was initiated by the CF due the high volume of operationally sensitive information being reviewed by disparate organizations, particularly pertaining to the operations in Afghanistan and the need to speak with one voice on matters of such potential injury. There was concern related to the Mosaic effect that could occur in the absence of oversight on the totality of sensitive operational information made available. The IST review is part of the 14 days allocated to the OPI to retrieve the records and provide the disclosure recommendations. IST is expected to use no more than 4 days of the 14 days allocated to each OPI to accomplish the review and provide the disclosure recommendations to the OPI who can then respond to the DAIP tasking.

4.4 – Please indicate whether this additional approval or review stage applies (1) to a specific type or category of requests, (2) systematically to all access requests or (3) on a case-by-case basis.

The IST review applies on a case-by-case basis to files that, in the opinion of the OPI, contain information related to operational security, which normally pertains to Canadian Forces Operations.

4.5 – Please indicate whether the roles and responsibilities of this approval or review stage are clearly established in a decision or a policy.

This review process was formally announced by the Strategic Joint Staff to all DND/CF organizations in a 13 June 2007 memorandum. The function of the IST as it relates to the ATI process is explained in section 3.9 of the DAIP SOPs (attached, as indicated in the response to question 3.7).

4.6 – In your opinion, has this other stage resulted in any increase in the delay to release the requested information?

Always

X

Almost always

Sometimes

Rarely

Never

Due to the high volume of requests for information related to the CF Operations the IST group has been inundated with records necessitating an OPSEC review. This is aggravated by the fact that the IST has other functions besides reviewing documents proposed for release under the ATIA. This additional review stage has severely hindered DAIP’s ability to respond within the legislated time limit.

5. Extensions Profile

5.1 – When an extension is taken under section 9, do you document on the file a rationale to justify the decision to invoke an extension? Please provide any relevant information to support the answer.

Yes. A rationale is prepared for each request and is documented on the ATI file, either in the ATIPflow notes, on the paper file, or both.

Part of the increase in extensions is due to an increase in requests. More requests equals more extensions, generally. We went from 1131 to 1779 in two years and our staff did not grow proportionally. The amount of files per analyst and the tendency of some applicants to submit large amounts of requests at the same time are also factors. We also have to take into account the complexity and sensitivity of requests pertaining mainly to Afghanistan for reasons of national and operational security. When many requests are received on the same subject it creates a logjam within those organizations receiving the requests and their capacity to respond in a timely manner is diminished as their backlog increases. This is particularly difficult for organizations who are concentrating on activities outside the country. In the past we have taken insufficient extensions for the circumstances. We now use a template for extension rationale that takes all factors into account more exactly.

5.5 – How do you determine the length of an extension taken under paragraph 9(1)(a) (“large number of records”)? What is the decision process used to determine the length of an extension? Please provide any relevant information to support the answer.

9(1)(a) extension length is determined primarily by contacting the OPI to get the information on the volume expected. The factors taken into account include the volume of records, the number of active requests, the average number of files per analyst, the number of active complaints, the number of files in deemed refusal and the number of active taskings for the OPI requesting an extension. Additional information provided to the OIC on June 27, 2008: "Active requests" is the number of requests that DAIPis processing at the time the extension is taken. "Active complaints" is the number of complaints active in the directorate at the time the extension is taken. I'm told that the director (who is currently on leave) was told in a meeting with members of your office to use this number as a factor. Another factor that may be added to the template is the number of active complaints currently being processed by the OPI organization. If a small group is overwhelmed by a large number of requests it will necessarily take more time to process.

5.6 – When extensions under paragraph 9(1)(a) (large number of records) are taken, are there any actions, practices or processes that your institution has implemented to ensure that the time limits to extension requests are met or delays are minimized? Please provide any relevant information to support the answer.

DAIP analysts are trained to make every effort to work with the applicants to re-focus requests that are likely to result in a large number of records. This includes dividing one large request into a number of smaller, manageable, requests. Analysts are also trained to take appropriate extensions that take all relevant factors into account so as to ensure that due date is achievable. Analysts attempt to ensure that the documents are forwarded to DAIP in a timely fashion by conducting regular follow-ups with OPIs who have files under a 9(1)(a) extension. Additional information provided to the OIC on June 27, 2008: By definition "dividing one large request into a number of smaller requests" increases the number of requests. It was explaining this in the context of an analyst encouraging the applicant to submit a number of smaller requests instead of one large one. This could help to avoid 9(1)(a) extensions in the first place or to minimize the amount of extension time required.

5.7 – Extensions under paragraph 9(1)(b) – Consultations

2005-2006

Number of days

ATIP flow does not distinguish between 9(1)(b) extensions taken by type of organization

5.8 – If consultations are taken under paragraph 9(1)(b),are these sent out as soon as the need has been identified?

Always

Almost always

X

Sometimes

Rarely

Never

5.9 – If necessary, please provide any relevant information to support the answer.

The consultations are prepared as the needs are identified. This usually occurs when review of the record is in process. Consultations are sent out as soon as possible, taking into account workload restraints such as the volume of files and volume of other consultations to prepare.

5.10 – How do you determine the length of an extension taken under paragraph 9(1)(b) (consultations)? What is the decision process used to determine the length of an extension? Please provide any relevant information to support the answer.

Determining factors include: The volume of the records to be consulted, the institution responsible and the days left to provide a response to the requester. Additional information provided to the OIC on June 27, 2008: Certain institutions simply take longer to respond. As can be seen in the answer to 3.5 above, the average PCO response time is 67 days. DFAIT also tends to take longer than average, particularly for those files requiring consultations with foreign governments. Often, we call ahead to find out how long we can expect to wait.

5.11 – When extensions under paragraph 9(1)(b) (consultations) are taken, are there any circumstances where for certain consultations, a certain amount of time is always taken by the federal institution to which the consultation is sent? Please provide any relevant information to support the answer.

No. The amount of time taken is determined by the volume and complexity of records as well as the organization to which it is being sent. Consultations with DFAIT and PCO tend to take longer so this is one factor that is considered.

5.12 – When extensions under paragraph 9(1)(b) (consultations) are taken, are there any actions, practices or processes that your institution has implemented to ensure that the time limits to extension requests are met or delays are minimized? Please provide any relevant information to support the answer.

A follow-up is done by the ATIP analyst directly with the institution in question as necessary. This is not possible for cabinet confidence consultations as those are now conducted between DND legal counsel and PCO legal counsel (a situation that has hampered the consultation process considerably).

5.14 – Are third party notices sentto third parties pursuant to paragraph 9(1)(c) and subsection 27(1) sent out before thirty days have lapsed?

Always

Almost always

X

Sometimes

Rarely

Never

5.15 – If you have not checked “Always”, please provide any relevant information to support the answer.

Occasionally the need to conduct a third party consultation may have been missed in the initial review. This is more likely with very large volumes of documents are involved.

5.16 –Are notices sent assoon as the need for the notice is identified?

Always

Almost always

X

Sometimes

Rarely

Never

5.17 – If necessary, please provide any relevant information to support the answer.

Due to large workload and the volume at hand, the process may sometimes be delayed.

5.18 – When an extension is invoked under paragraph 9(1)(c) for third party notification, how often does the institution meet the statutory timelines? Please provide any relevant information to support the answer.

Always

Almost always

Sometimes

X

Rarely

Never

The cooperation or comprehension of the third party is not always forthcoming and follow-up is sometimes required. There may also be volume issues.

5.19– When extensions under paragraph 9(1)(c) (notices to third party) are taken, are there any actions, practices or processes that the federal institution has implemented to ensure that the time limits to extension requests are met or delays are minimized? Please provide any relevant information to support the answer.

A BF system is in place. Follow-ups with the third are also done.

5.20 – When extensions are taken under paragraphs 9(1)(b) and / or 9(1)(c) – consultations – does the ATIP Office provide a partial release of the requested records for portions of the request that are not involved in the consultation process?

Always

Almost always

Sometimes

Rarely

X

Never

5.21 – If necessary, please provide any relevant information to support the answer.

Partial releases are done only further to the insistence of the requester and when it is reasonable to do so. Partial releases add to an already heavy workload. In some instances they may be premature particularly in cases of outstanding consultations.

6.1 – When a discretionary exemption is claimed, is a rationale prepared to support the decision to exempt information?

Yes

No

X

Please provide any relevant information for this question.

The OPI guidance sheet that is provided to each OPI with the tasking indicates that where the reasons for severance are not self-evident a rationale is to be provided. The analyst may also add comments in ATIP Image. The responsibilities of all parties to provide and document rationale for severances are detailed in the DAIP SOPs. The requirement and process to provide rationale is also explained in detail during the training sessions provided by the DAIP Policy and Training Team.

6.2 – When a discretionary exemption is claimed, is it exercised in the context of jurisprudence and practice?

Yes

No

X

Please provide any relevant information for this question.

6.3 – Is there a documented requirement to prepare a rationale when a decision is made to claim a discretionary exemption?

Yes

No

X

Please provide any relevant information and documentation for this question.

Please see 6.1.

6.4 – Is the discretionary exemption rationale prepared by the OPIs and/or the ATIP Office?

Yes

No

X

Please provide any relevant information and documentation for this question.

Please refer to 6.1. Initial rationale is normally provided by the OPI but the rationale may be documented in further detail by the ATIP office, particularly when the initial rationale is not clear or supported by the analyst and a follow-up with the OPI is required.

6.5 – Is there a documented discretionary exemption challenge function in ATIP Office if the rationale is prepared by OPIs?

Yes

No

X

Please provide any relevant information and documentation for this question.

This is part of the role of the ATIP analyst as explained in the DAIP SOPs.

Please provide any relevant information and documentation for this question.

It is part of the ATIP analyst function to evaluate all rationales provided by the OPI as detailed in the DAIP SOPs but it is not necessary to “challenge” a rationale that is obviously correct or clearly supported.

B. DEEMED-REFUSAL REQUESTS

Part I: Requests carried over from the 2006-2007 fiscal period.

1.

Number of requests carried over:

436

2.

Requests carried over from the previous fiscal period — in a deemed-refusal situation on the first day of the new fiscal period:

10

Part II: New Requests — Exclude requests included in Part I.

3.

Number of requests received during the 2007-2008 fiscal period:

1779

4.A

How many were processed within the statutory 30-day time limit?

524

4.B

How many were processed beyond the statutory 30-day time limitwhere no extension was claimed?

46

5.

How many were extended pursuant to section 9?

1129 581 Extended & Completed 548 Extended & Active

5.A

How many were extended pursuant to paragraph 9(1)(a)?

1003

5.B

How many were extended pursuant to paragraph 9(1)(b)?

286

5.C

How many were extended pursuant to paragraph 9(1)(c)?

95

6.A

How many were processed within the extended time limit? (re Row 5)

403

6.B

How many exceeded the extended time limit? (re Row 5)

178

7.A

How many were processed within the extended time limit? (re Row 5.A)

579

7.B

How many exceeded the extended time limit? (re Row 5.A)

424

8.A

How many were processed within the extended time limit? (re Row 5.B)

224

8.B

How many exceeded the extended time limit? (re Row 5.B)

62

9.A

How many were processed within the extended time limit? (re Row 5.C)

95

9.B

How many exceeded the extended time limit? (re Row 5.C)

0

10

Number of requests in a deemed-refusal situation as of March 31, 2008,

1. – Is the ATIP Coordinator responsible exclusively for the administration of the ATIP Office?

Yes

X

No

2. – If No, please list other responsibilities of the ATIP Coordinator.

3. – When requests processing stages, other than those listed in section A.4 of this questionnaire, are in place, who has the designated authority to make decisions on the disclosure or refusal to disclose information under theAccess to Information Act(s. 73)?

The question is awkwardly worded but the response is: The Director and Deputy Directors have designated authority. In their absence the designation order allows for decisions to be made by the Director General Corporate and Shared Services or the Assistant Deputy Minister (Finance and Corporate Services). – Respectively one and two steps up in the chain of command from the Director. However, during the last year, there were no occasions where directors and/or Deputy Directors were not available and so the DG and ADM did not exercise any authority in this regard and it is unlikely that a situation would occur whereby the DG or ADM would be required to exercise their authority in this regard.

E. SPECIFICS FOR 2007-2008

In this section, the institution is asked to provide details relating to the information provided in response to the questionnaire:

1. – Please describe the most significant issues that affected your institution's ability to (i) respond to access to information requests as quickly as possible and/or (ii) provide requesters with as much of the information requested as possible.

Volume of requests Rate of increase in volume of requestsLack of staff and accommodations for new employees. DAIP is attempting to acquire larger accommodations because we have outgrown our current location. This limits DAIP’s upper limit of employees - Requests have been made to PWGSC for additional office space for DAIP. Lack of experienced staff – This is due to a high turnover, which is itself caused by burnout and losing staff to better offers from other institutions. Even when we hire replacement staff they have a relatively long learning curve before they can process complex requests. The time spent training new staff also interferes with the work on requests. High rotation rate of OPI and Subject Matter Experts (SMEs) – DND probably has a turnover rate comparable to other departments. The CF turnover is likely higher as CF members can be posted all across the country or even out of the country as determined by the chain of command. Determining the appropriate person to review records as a SME can be problematic. Complexity and sensitivity of content (particularly with operational security issues) – This necessitates a longer review time on behalf of the analyst and requires the OPI to consult with SJS IST, both of which prolong the entire process.Accessibility of records (i.e. in a war zone)

2. – For the issues identified in the response to Q. 1 above, were they foreseeable? Please explain.

Most were foreseeable to varying degrees particularly those regarding staff shortages and rotation rates. The increase in volume has probably accelerated faster than would have been anticipated and DAIP did not foresee the creation of SJS IST.

3. – Please describe any best practices developed / undertaken by your institution to improve your delivery of the access to information program. If possible, please indicate how successful these practices have been.

Implementation of a Tasking Team to free the ATI analysts and afford them more time to review the records. An employee development program is underway with an aim to favor employee retention by providing greater opportunities within DAIP. The program is based on process of intake of analysts at entry level and providing them with promotions without competition based on them achieving specific performance goals.

G. COMPLAINT PROFILE

Data supplied by the Office of the Information Commissioner on complaints made to its Office and the resolution of those complaints.